Market Advisory August 26, 2014 FATCA Loan Amendments and Determining Grandfathered Status FATCA withholding tax does not apply to payments made with respect to a loan that was outstanding on July 1, 2014. By definition, these loans are “grandfathered” obligations. Grandfathering status will be lost, however, if such loans undergo a “significant modification” under Treasury...
Operations & Standards, Tax and accounting resources
Implementing FATCA Neal Givner, Credit Suisse Dennis Kelly, Winston & Strawn May 8, 2014 FATCA in General Enacted in March of 2010. Requires each foreign financial institution (“FFI”), including CLOs and other offshore investment funds, to obtain identifying information from its U.S. account holders which the FFI will forward (directly or indirectly) to...
Operations & Standards, Tax and accounting resources
FATCA: What You Need to Know Neal Givner, Credit Suisse Dennis Kelly, Winston & Strawn Kevin Sullivan, BNP Paribas April 8, 2014 What Is FATCA Enactment The Foreign Account Tax Compliance Act provisions, generally referred to as “FATCA”, were included in the Hiring Incentives to Restore Employment (“HIRE”) Act passed in March 2010...
Operations & Standards, Tax and accounting resources
LSTA submitted a letter to the IRS and Treasury supporting the letter submitted by ISDA on August 28, 2013 as it pertains to FATCA’s reporting requirements for CLOs....
